Citizens for the Preservation of St. Augustine (CPSA) is deeply concerned with the progression of Ordinance 2017-12 to second reading scheduled for July 10, 2017. CPSA’s charter is to protect the historic assets of St. Augustine that contribute to the City’s image and character, to preserve the character of our individual and unique neighborhoods, and to promote preservation wherever and however possible.

Confirmation of this amendment will undermine the very purpose of zoning and weaken the confidence of St. Augustine residents’ in the consistent and fair application of regulations. The first reading on June 12th left many with the feeling that residents’ concerns were hastily dismissed by the City, neighborhood character was unimportant, and, once again, our HP zoned properties were for sale to the highest bidder.

This PUD was created six years ago to serve building the San Marco Hotel, because hotels are not allowed in HP5. Granting of this PUD ceded 12% of HP5 to one person. Approval of the amendment cedes another 3%, giving one person control of 15% of HP5. It has not gone unnoticed that the properties are non-contiguous, setting up another disturbing precedent for others to request a patchwork PUD. This developer owns other property in the same district (1 Riberia St.) and has had discussions to acquire additional property.

HP5 was established in the ‘70s to prevent exactly what is happening in this ordinance.

PZB’s rationale was sound and without error. You have heard from two members of the PZB who contest your position on this. You are sending a message to citizens that regulations can be easily overridden despite the decisions of the PZB. And, you are ignoring the documented position of the closest neighbors: 88% of the surveys returned from homes in the immediate neighborhood objected. While we understand that the survey results have been questioned, concerned citizens have shown that the results are all from unique households within 3 blocks of the proposed hotel. Clearly, these responses were from impacted citizens and represent a valid majority of the neighborhood.

While understanding that PUDs are not required to comply with established occupancy/parking ratios, in practicality a PUD must provide adequate parking to protect the vicinity from bearing its peak time overflow. Use of valet parking does not change the potential for incoming traffic to back up into the street. Combine a weekend event at Francis Field and a 500-person event at the San Marco Hotel and traffic will be backlogged at critical intersections. These risks of this scenario to the safety of pedestrians and cyclists should not be ignored. If the City proceeds with recommendations from the mobility initiative to use dedicated shuttle routes down San Marco to the parking garage, even more traffic challenges should be expected.

Additionally, nothing has been demanded of the developer for archaeological investigation during the construction phase. The property in question is one block from our Colonial City Gate and could hold many secrets from our past. The same developer in a previous project at the current Hilton Hotel site allowed scant access for archaeologists to fulfill their mission. The Hilton location was the site of a major waterfront trading post in the 18th century, but only minor archaeological investigations preceded construction. Valuable cultural data was lost.Archaeological access should be a condition of any PUD. We have distinguished archeologists in the City who can determine a fair and reasonable extent of any dig.

CPSA takes the position that Ordinance 2017-12 sets a dangerous precedent, has been denied by the PZB, and should not be overturned by the City Commission. The developer’s documented occupancy data and the City’s minimum parking requirements have been reduced since origination. The numbers shown on the original plans and those given at PZB hearings are different. The Developer now wishes to change his original 100% underground parking design (and likely save significant construction costs) since surface parking became a possibility with the purchase of additional property in 2017. Granting the PUD Amendment for surface parking only favors the Developer and conflicts with City Zoning and its Comprehensive Plan. The City cannot subsidize incomplete engineering and planning decisions by any property owner. Our City’s credibility in the consistent application of zoning regulations both in historic preservation districts and at large will be compromised by the passage of this PUD amendment. Proper vetting of the developer’s data should be required before further consideration of this amendment.

Our City’s credibility in the consistent application of zoning regulations both in historic preservation districts and at large will be compromised by the passage of this PUD amendment. The intentions of the City Commission to uphold city regulations, preserve neighborhoods and foster improved mobility will be demonstrated clearly by your actions. We ask that you deny this request for the rezoning of HP-5 and the amendment of the existing hotel PUD.